Final regulations issued by the IRS and Treasury allow a Sec. 754 election statement to be submitted without a partner’s signature.
Partnership and LLC Taxation
This item considers to what extent taxpayers may be able to apportion basis instead under Sec. 704(c) principles.
This item provides an overview of the division rules and touches on some key issues to consider when a transaction involves a partnership division.
When LLC members receive payments for services performed for the LLC, the tax treatment depends on whether the member is performing the services in the capacity as a member.
An insufficient understanding of the rules can be dangerous to taxpayers when determining which entity has a filing responsibility in Tennessee.
This item discusses how owners selling partnership interests should address which states may attempt to tax the entire gain, how taxation of the gain may be divided among the states where the partnership does business, compliance considerations, and technical developments and trends that may affect the transaction.
No deduction is allowed in the year of sale of a basketball team for deferred compensation owed to two of the team’s players.
In eight new FAQs on its website, the IRS covers some special issues, including several that it says will be added to the forms’ instructions.
The Treasury Inspector General for Tax Administration recommends setting goals and benchmarks for the centralized audit regime under the Bipartisan Budget Act.
Comment letters from the AICPA and state CPA societies also offer further recommendations.
The new schedules for returns of passthrough entities with international items have been greeted with antipathy by practitioners. The IRS provided relief Wednesday for eligible entities for tax year 2021.
What partnerships, S corporations, and others with foreign partnership interests need to know for tax year 2021 and beyond.
The discussion covers developments in the determination of partners and partnerships, gain on disposal of partnership interests, partnership audits, and basis adjustments.
Partnerships and their partners need to work closely to maintain strong communications to overcome challenges to information sharing and, ultimately, to computational matters and information reporting.
When an LLC interest is transferred, the transferee’s basis depends on the transferor’s basis and numerous other potential factors.
Taxpayers should strongly consider these letter rulings when trying to determine whether they want to structure a borrowing with a regarded entity as the legal borrower or whether they prefer to have a DRE be the legal borrower of the debt.
A law change and some regulations take effect while an array of provisions expire.
Forgiveness amounts are excluded from gross income but included in gross receipts for purposes including determining “small business taxpayer” status under Sec. 448(c).
The IRS posted FAQs with sample worksheets and instructions for taxpayers to use when calculating and reporting certain net long-term capital gains from partnership interests held in connection with the performance of services that must be recharacterized as short-term capital gains.
Microcaptive insurance arrangements have been vigorously scrutinized recently by the IRS.